Ashley Franklin v. Franklin Cnty., Ky., 115 F.4th 461

Ashley Franklin, an inmate at Franklin County Regional Jail, was sexually assaulted by Sergeant Brandon Price during a medical transport in January 2019.
Franklin sued Price, Franklin County, Captain Culbertson, and Jailer Rogers under 42 U.S.C. § 1983 for constitutional violations and also for various state law claims (including negligence and gross negligence).
Summary judgment was granted in Franklin's favor against Price for the Eighth Amendment claim, but the district court granted summary judgment in favor of the other defendants on all other claims.
The court found no municipal liability under Monell theories for Franklin County and qualified immunity for the individual defendants for the remaining claims.
On appeal, Franklin challenged adverse summary judgment rulings against the County and the individual defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
County liability for sexual assault (Monell)	County’s customs/policies enabled the assault; failure to prevent, detect, train, or supervise.	Policies/training exist; Price’s conduct was rogue, not policy-driven.	No liability; no direct causal link to an unconstitutional policy/custom.
County liability for inaction	County ignored prior sexual misconduct, allowing culture of indifference.	Prior events insufficiently similar; no persistent pattern or causation shown.	No liability; no “pattern” or “moving force” shown.
Failure to train/supervise	County failed to train/supervise staff on PREA and sexual assault prevention.	Training and written policies existed and were applied; annual PREA training required.	No liability; policies and training deemed constitutionally adequate.
Deliberate indifference of supervisors	Culbertson should have prevented lone male transport or reassigned a female staff; inferred risk.	No knowledge of specific risk; no policy of only female transports; no violation alleged.	No deliberate indifference; no evidentiary support for subjective knowledge.
Individual negligence/gross negligence	Supervisors failed to enforce transportation and PREA policies.	Actions were discretionary, not ministerial; qualified immunity applies.	Qualified immunity under Kentucky law; claims dismissed.

Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (a municipality may only be held liable under § 1983 where a policy or custom causes the constitutional violation)
City of Canton v. Harris, 489 U.S. 378 (municipal liability for failure to train only where training is inadequate due to deliberate indifference)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard for prison official liability for inmate safety)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard requirements for genuine dispute of material fact)